Cameras & Facial Recognition Policy

1. Who we are

Paradigm Consulting LLC d/b/a The Break Room, 79 Danbury Rd, Ste A-1, Ridgefield, CT 06877. We are responsible for the cameras in our store and for the data they collect. Contact us at info@breakroom.cards or (203) 544-3886. This page covers our in-store cameras only; our Privacy Policy covers our website and online orders.

2. What our cameras collect

• Video. Three cameras record the sales floor and back room continuously, including when the store is closed. They do not record sound: their microphones are switched off.
• Face data. The camera system detects faces in the video and measures facial features so it can tell whether it has seen the same face before. Those measurements are biometric data. The system groups detections of the same face together under a random reference number.
• Person detections. The system also detects people as figures moving through the frame, without looking at their faces or recognizing who they are. These are what we count visitors from.
• Names, for staff and family only. We have named the faces of our own staff and family so the system recognizes them. We do not name customers, and we do not try to find out who an unnamed face belongs to.
• Vehicles. The front camera can see part of the parking lot through the windows, so it also detects cars and license plates there. We use these only as counts, never to look anyone up.

3. Why we use it

• Security. To prevent, detect and respond to theft and other security incidents. When the store is closed, we are alerted if the cameras see activity and no member of our staff is recognized.
• Leaving our own staff out of visitor counts. When the system recognizes one of our staff at the door, that crossing is left out so we don't count ourselves as customers. It does this only for staff who have given us their written consent.

Those are the only things we use face data for. Customers' faces are used only for security, never for counts. Faces are matched only against our own database, which lives on our own recorder in the store. We do not compare faces against any outside or shared database, and we do not keep a watch list of customers.

Visitor counts. Separately, we count how many people come in, by hour and by day, and how long people spend in each part of the store. These counts come from person detections and a counting line at the door, never from customers' faces. The one exception is our own staff: when the system recognizes one of us at the door, that crossing is left out so we don't count ourselves. The counts cannot tell whether someone has visited before, and we only ever see totals, never who.

4. What we never do

• Sell, rent or trade face data, video or any other personal data.
• Share face data with other businesses, advertisers or data brokers.
• Link face data to your name, your purchases, your online account or your email address.
• Use it for advertising, marketing or profiling.
• Use it to train AI models, including large language models.

The one exception is video: if a crime happens at the store, or the law requires it (for example, a subpoena), we may give the relevant clip to the police or a court.

5. Where it is kept, and who can see it

• Video and face data are stored on our camera recorder (a UniFi Protect system), which is physically in the store. Only the store's owners can view it, in person or through UniFi's encrypted remote-access app.
• For visitor counts and after-hours alerts, a private tool we run ourselves reads the recorder's detection log. For counts it reads person detections and door-line crossings; the only face information it uses is whether the recorder recognized a member of our staff at the door, so staff are not counted as visitors. For the alert it checks only whether the recorder recognized a member of our staff. It keeps daily totals and nothing else: no reference numbers, no names, no images, no video and no face measurements.

6. How long we keep it

7. Your rights

Under the Connecticut Data Privacy Act you can ask us to:

• Tell you what we hold. We will confirm whether we hold face data or video of you. The law does not allow us to hand over biometric data itself, so we will describe what we hold rather than send it.
• Delete it. We will delete your face data and any video of you we can find, unless we need a specific clip for a security incident or legal claim, in which case we will tell you so.
• Correct it, if something we hold about you is wrong.
• Withdraw consent. If you have given us consent, you can withdraw it just as easily, and we will stop within 15 days.

The cameras cannot skip one person, so while you are in the store they will detect your face like everyone else's. What we can always do is delete it afterwards. We do not sell personal data or use it for targeted advertising or profiling, so there is nothing to opt out of there.

How to ask. Email info@breakroom.cards with the subject “Camera privacy request”, call (203) 544-3886, or ask us at the counter. Faces in our system are unnamed, so to find yours we need to know roughly when you visited; if you are in the store we can look it up with you there. We will not ask for more than we need to find your data, and we will delete anything you send us for that purpose once your request is done. Requests are free, and we will never treat you differently for making one.

When we will answer. Within 45 days. If we need longer, we will tell you why within those 45 days; the law allows up to 45 more.

If you disagree with our answer. Email us with the subject “Camera privacy appeal”, or tell us in the store. We will give you a written decision, with our reasons, within 60 days. If we turn down your appeal, you can complain to the Connecticut Attorney General (below).

8. Connecticut Attorney General

You can contact the Office of the Attorney General about our use of facial recognition or any other privacy concern:

• Office of the Attorney General, 165 Capitol Avenue, Hartford, CT 06106
• Consumer Assistance Unit: 860-808-5420 · General inquiries: 860-808-5318
• Online complaint form: dir.ct.gov/ag/complaint (choose “Consumer Data Privacy”)
• Email: attorney.general@ct.gov

9. Changes to this policy

If we change how we use our cameras, we will update this page and the date at the top before the change takes effect. Notices with a link to this page are posted at every customer entrance.